SecProbe.io

September 28, 2011
 Via E-mail

Mr. Christopher Lucas Group Finance Director Barclays PLC 1 Churchill Place London E14 5HP  England
Re: Barclays PLC
Form 20-F for Fiscal Year Ended December 31, 2010 Filed March 21, 2011 Form 6-K  Filed August 2, 2011
  File No. 001-09246

Dear Mr. Lucas:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  Where we have requested changes in  future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosu res.  If you do not believe our
comments apply to your facts and circumstances or  do not believe an amendment is appropriate,
please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.               Form 20-F for Fiscal Year Ended December 31, 2010

Business Review
Analysis of results by business
Barclaycard, page 23

1. You indicate that you experienced an increase in risk weighted assets, which reflected
securitization redemptions.  Please revise fu ture filings to clar ify why securitization

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 2

 redemptions would increase risk weighted a ssets.  In your disclosure, please clarify
whether you are repurchasing loans from your  securitization vehicles and explain the
reasons why you have taken such actions.  Clar ify if the securitizati ons of these assets
were previously recognized as a sale or a secured financing in your financial statements.
Additionally, please tell us how  you considered these redemptions in your analysis that
the assets should continue  to be derecognized.

Western Europe Retail Banking, page 25

2. In 2009, you completed the purchase of Citigroup’s cards business in Portugal, which
consisted of 400,000 customers and loans and advances to customers of £550 million.  In 2010, you completed the purchase of Citigroup’s It alian card business, which consisted of
200,000 customers and loans and advances of £0.2 billion.  You recognized a relatively
similar gain on both transactions of £26 m illion related to the purchase of the cards
business in Portugal and £29 million related to the purchase of the card business in Italy.
Please tell us the factors considered in determ ining a purchase price that resulted in a gain
on these two transactions.  Di scuss the similarities between these two portfolios in credit
trends and the associated purchase discount  recorded on them.  Tell us how these
portfolios have been performing since acqui sition and whether this performance is
consistent with your exp ectations upon purchase.
 Absa, page 29

3. Your disclosure indicates that the increase in the asset margin of Absa was due, in part, to
a change in the product mix as higher margin  products grew faster than low margin
products.  Please revise your future filings to disclose what types of products you are
referring to.  If these products  include loans and advances with  higher risk characteristics,
please include a discussion of how this ch ange in your business mix and the related
assumption of risk related to higher margin loans and advances was considered in your
determination of the appropriate allowance for loan losses.

4. We note your disclosure that ri sk weighted assets for this segment increased 42% due in
part to enhancements to the retail model.  Pl ease revise your future filings to expand your
disclosure regarding the types of enhancements to the retail model.  Discuss if the
enhancements caused you to identify certain as sets as having a higher risk weighting than
you originally assigned and discuss the impact the change in your model had on your
capital ratios. Clearly identify how much of th e increase in risk we ighted assets was due
to the growth in higher margin products noted above.
 Barclays Capital, page 31

5. We note your disclosure regarding the 35% decline in the top line income of Fixed
Income, Currency and Commodities.  Please respond to the following:

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 3

 Please tell us in greater detail the types of commodities in which you invest
specifically identifying the commodities in which you take physical possession,
the activities that go into making a market  in these commodities , and the types of
revenue streams earned as a result of these activities.

 Tell us how you obtained your ownership of the various commodities you own,
and tell us whether this is an area where you are considering further investments.

 Tell us whether you hold concentrated positions in or take physical possession of
commodities that constitute a significant or influential share of the market for that
commodity.  If so, revise your future filings  to discuss that fact and your activities
in that area.
 Credit Risk Management

Impairment allowances, page 73

6. You indicate on page 175 that the “other personal loans” category includes second lien
loans, along with other types of personal loans.  Please tell us  and revise future filings to
disclose the balance of second lien loans held  by you at the end of the reporting period.
If delinquency and other credit trends for second lien loans differ from other types of
personal loans in this category, please consid er reporting that information separately for
second lien loans.  Otherwise, tell us how  you determined such delinquency and credit
quality trends were substantially the same.  Please also address the following:

 Disclose the loss severity on these loans wh en you determine that a write of the loan
or a portion of the loan is necessary.
 Please provide a breakdown of your second lien  loans into two buckets to quantify the
amount of loans where you hold the first mort gage security intere st as well as the
second lien versus where you hold only the second lien home equity loans.

 Tell us the amount of second lien home equity  loans where you act as the servicer on
the first mortgage loan.

 Describe the terms of the home equity loans in more detail.  For example, tell us how
long the draw periods are for the loans and provide more quantitative data on when the loans convert to amortizing.

 Tell us whether you are able to track whethe r the first lien position is in default,
regardless of whether you hold the first lien lo an.  If so, please tell us the results of
that data and consider providing disclosure  of this information in future filings.

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 4

  Tell us whether the default and delinquency st atistics for the home equity loans where
you also hold the first lien show a different  trend than situatio ns where you service
the first security lien compared to those wh ere you do not also hold or service the first
lien loan.  If so, consider the need to di sclose and discuss the existence of such a
trend.
 Tell us whether the default and delinquenc y statistics for amortizing loans show a
different trend than situati ons where the home equity lo ans have not converted to
amortizing.
 Renegotiated loans and advances, page 84

7. Please revise your future filings to addre ss the following regarding your renegotiated and
restructured loans:

 We note the definitions of restructured loans and renegotiated loans provided on page
305.  Please revise those secti ons as well as this section to more clearly explain and
differentiate your usage of these terms.

 For the purposes of showing trends in these t ypes of assets over the periods presented,
please provide a tabular disc losure of the amounts of re negotiated and restructured
loans by loan class, i.e. retail, wholesale, etc.

 Clearly disclose when a loan is remove d from renegotiated loan status and/or
restructured loan status, and which of thes e loans are treated as new loans such that
their past due status is reset.   Clearly identify the types of  loan modifications that are
not considered to be renegotiated or rest ructured loans, and explain why not.

 Please revise to disclose the carrying amount of financial assets that would otherwise
be past due or impaired whose terms have  been renegotiated by class pursuant to
paragraph 36(d) of IFRS 7 in an audited se ction of the document, or tell us where
such disclosure is provided.

 Revise to more clearly identify what th e amounts presented in your line items for
“impaired and restructured loans” on pa ges 176-177 are meant to represent.

 Revise to disclose the quantitative a nd qualitative factors considered when you
determine whether or not a modificati on is significant enough that you would
extinguish the original loan and record a new loan.

 Clarify if you consider loans included in your retail forbearance programmes
discussed on page 80 as renegotiated loans.

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 5

 Corporate loans, page 84

8. We note your disclosure that collateral given for these loans is only accurately valued on
origination of the loan or in  the course of enforcement ac tions and as a result it is not
practicable to estimate the fair value of the co llateral held.  Please re vise your disclosure
in future filings to explain how you consider the lack of revaluati on between the time of
origination and the time that an enforcem ent action is underway when determining the
appropriate amount of allowance for loan lo sses.  Discuss the trends in the amounts
charged-off when you have completed the enfo rcement action as a re sult of property or
other collateral values that are less than th e value assigned upon orig ination of the loan.
 Liquidity Risk Management

Global Retail Banking, Barclays Corporate, Barc lays Wealth and Head Office functions, page
108

9. Footnote “a” to the behavioural maturity profile of assets and liabilities tabular disclosure
on page 109 indicates that  within the category of “not more  than 1 yr” you have included
£18.1 billion of Group liquidity pool assets that  have a contractual maturity of greater
than one year but can be used to generate short-term cash flows either through sale or
secured lending.  Please revise to provide an expanded explanation of this disclosure.  In
this regard, we note that the £18.1 billion disclo sed in footnote “a” is larger than the total
outflow reported for the entire category.  A dditionally, please discu ss in greater detail
why this presentation is more meaningful than presenting assets according to their
contractual maturity.
 Supervision and regulation, page 115

10. We note your disclosures on page 119 regarding th e potential impact of the Volcker Rule.
Please tell us whether you have conducted an  analysis of what you believe the potential
effects of the Volcker Rule will be on your operations and whether you believe it could
have a material effect.  Also, to the exte nt reasonably known, in future filings please
quantify the amount of historical proprietary revenues which you believe could be subject
to restrictions once the rulemaking is finalized.
 Consolidated financial statements

Consolidated statement of changes in equity, page 189

11. We note you present a statement of change s in equity covering 2009 and 2010.  Please
revise your future filings to  present the changes in equity for three complete years
pursuant to Item 8.A.1 and .2 of Form 20-F.

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 6

 Notes to the financial statements

1.  Significant accounting policies
8. Impairment of financial assets, page 197

12. Please revise your disclosure in future f ilings to provide a summary of the factors
considered when determining that a loan is  individually significant for the purposes of
assessing impairment.
 19. Insurance contracts and inve stment contracts, page 201

13. Please tell us and revise future filings to identify the generally accepted accounting
principles (e.g. U.K., U.S., etc.) you look to in developing your accounting policy for
your insurance activities.  Please ensure your response addresses how this developed
policy complies with the guidance and principles outlined in paragraphs 10-12 of IAS 8 and paragraph 14 of IFRS 4.

14. Revise to more clearly disclose the extent  to which you report your reinsurance balances
on a gross versus net basis.  Refer to paragraph BC106 of IFRS 4.

24. Provisions, page 224

15. We note your rollforward of the four classes of provisions reported he re as well as your
statement at the end of Note 24 that the provisi ons with respect to litigations are included
in the Sundry provisions.  Please revise your future filings to address the following:

 Revise Note 24 to provide the narrative disclosures required by paragraphs 85-86 of
IAS 37, and more clearly identify the nature  of classes that ar e aggregating within
your rollforward in Note 24.  To the exte nt your disclosures pr ovided in Notes 25, 26,
and 27 are meant to meet these narrative di sclosure requirements, please revise to
more directly and transparen tly link your narrative disclosure in Notes 25, 26, and 27
to the amounts and classifications presented in Note 24.  Refer to paragraph 88 of IAS
37.

 As part of your response, tell us in detail  the nature of the various items included in
each of your classes.  Please provide a tabular breakdown of the amounts you are
aggregating in each class.

 From the last sentence of Note 24, it a ppears you are aggregating your litigation
provisions class within your  Sundry class of provisions . In determining that the
various exposures may be aggregated togeth er with your litigati on exposures to form
a single class, tell us how you determined that  the nature of these items is sufficiently
similar to fulfill the requirements of paragraphs 85(a) and (b) and 86(a) and (b) of IAS 37.  Refer to paragraph 87 which indica tes that while it may be appropriate to

 Mr. Christopher Lucas Barclays PLC September 28, 2011 Page 7

 include warranty provisions for different pr oducts as a single cl ass, it would not be
appropriate to include warranties and litig ation provisions in the same class.

 From the disclosures on page 225, it appear s you have recorded provisions for and
may have contingent liabilitie s for recourse obligations pursuant to loan sales and
loan securitizations.  Revise your future filings to disclose which class these amounts are presented in, and tell us in detail how  you determined that such amounts were
sufficiently similar to the other amo unts presented in that class.

 Clearly identify where your Provisions for re gulatory matters as discussed in Note 27
are reflected in the rollforward of  Provisions by class in Note 24.
 25. Contingent liabilities and commitments, page 225

16. Please address the following regarding your gene ral disclosure at th e bottom of page 225
that, “It is not possible to provide a meaningf ul estimate of the fina ncial impact of the
potential exposure relating to all of the forgoing matters at this time”:

 Tell us and revise your future filings to mo re clearly explain wh at you mean here.

 Clearly identify how you define “meani ngful” and how it complies with the
applicable threshold guidance in IAS 37, including paragraphs 25-26 regarding a
“reliable” estimate.  It is unclear whether your disclosure is meant to convey that you
use a different standard for determining wh en a loss is estimable than the standard
describes in paragraphs 25- 26 of IAS 37 which indicates that except in “extremely
rare” cases, a registrant woul d be able to determine a range of possible outcomes and
thereby make an estimate of the obligation that is suffic